November 27, 2013 at 4:00 pm EST
#4433
rcooper
Member
The small creditor QM refers to c(7) under the general ATR rules. There are special rules there for balloon, interest only and neg. am loan but it doesn’t mention deferred payments in general or student loans. Appendix Q does address deferred/student loans, but Appendix Q doesn’t technically apply to the small creditor QM.
Jack may offer some insight on this.